Privacy Policy

This Privacy Policy for the Promotion (‘the Promotion”) applies to individuals who participate in the Promotion. This Privacy Policy also applies to our website (the “Site”), located at www.cosigames.com. Cosi Productions LLC and our affiliates (“Cosi” or “we”) are committed to protecting the privacy of all individuals using our Site or participating in the Promotion.

This Privacy Policy was last updated on April 2, 2016. We may change this Privacy Policy from time to time so please check back regularly to keep informed of updates. If you do not agree to this Privacy Policy or any changes to this Privacy Policy, please do not participate in the Promotion or visit our Site. Any participant information collected during the Promotion or by email shall be used only in a manner consistent with this Privacy Policy. By participating in the Promotion or accessing our Site each Participant expressly agrees to the use of his/her Personal Data for such purpose

Personal Data

Personal Data is information about you that you provide to Cosi and that is personally identifying, such as your name, address, email address, date of birth, or phone number, and that is not otherwise publicly available.

Collection and Use of Personal Data

When you register for the Promotion through the Application Pele: King of Football (the “Application”), we collect your email address so we may contact you if you win a prize. If you register for the Promotion by email instead, we collect your email address, first and last name, date of birth and country of residence in order to verify your eligibility for the Promotion and to contact you if you win a prize. We also collect your email address if you email our website for information so we may respond to your inquiries. If you are selected as a potential winner for a prize, we collect information necessary to verify your eligibility for the prize, verify your identity, and mail the prize to you. This may include your first and last name, postal address, telephone number, date of birth, and/or a copy of a photo ID that establishes your identity. Our collection of Personal Data is limited to the collection of necessary and adequate information required to accomplish the purposes described above. When you provide Personal Data, it is being provided directly by you to Cosi Productions LLC.

Your information will be retained as long as necessary to notify you, award a prize, confirm a prize has been received, and to perform follow-up activities related to the Promotion. Follow-up activities may include contacting winners to participate in certain activities related to the Promotion.

How do we Protect Your Information?

We implement a variety of security measures to maintain the safety of your information when you enter, submit, or access your information.

100% Opt-In

Participation in the Promotion and provision of Personal Data is by opt-in only. You can opt-in by registering for the Promotion through the Application or by email. If you do not opt-in you will not participate in the Promotion or be eligible to win a prize. By opting in you are providing your express consent to the collection, use, retention, processing and transfer of your Personal Data as explained in this Privacy Policy.

You can also opt-in to receive an answer to a question by sending us an email, in which case we will collect your email address to respond to you. By sending an email to us you are providing your express consent to the collection of your email address and any other Personal Data you provide to us by email. If you don’t opt in, we will not respond to you.

Your Consent

By emailing us, by opting-in to register for the Promotion, and/or by opting in to our collection of your information in order to receive a prize, you expressly consent to the collection, use, retention, transfer and disclosure of your information as described in this Privacy Policy. Each time you email us, register for the Promotion or participate in the Promotion you are giving your express consent to the collection, use, retention, transfer and disclosure of your information as described in this Privacy Policy.

If you wish to withdraw your consent, you may do so at any time by writing to: info@peleapp.com. If you withdraw your consent you will no longer be eligible to participate in the Promotion or to win a prize, and we will not have any means by which to respond to your questions or comments that you email to the Site.

International Transfer of Your Personal Data and Your Express Agreement

Given that the Internet and mobile applications operate in a global environment, using the Internet and mobile applications to collect and process Personal Data necessarily involves the transmission of data on an international basis. By registering for the Promotion and/or communicating with us by email, you acknowledge and expressly consent to our processing of your Personal Data in this way.

Participants’ Personal Data will be transferred outside of each eligible country to the United States where it will be processed and stored. The U.S. does not provide an adequate level of protection according to EU data protection regulations, for the purpose of administering this Promotion. Cosi will take all steps reasonably necessary to ensure that participants’ Personal Data is treated securely and in accordance with this Privacy Policy and the Terms and Conditions for the Promotion in respect of such transfer, but will not otherwise take steps to ensure compliance with applicable laws in the participants’ country of residence. By participating in the Promotion, participants expressly agree to such transfer.

Contact Us About Concerns or to Change or Delete Your Information

Participants have a right to access, update, change and delete their Personal Data at any time. To exercise such right, a participant may write to info@peleapp.com; or by mail at 11-11 44th Drive Long Island City, NY 11101 (“Data Controller” and “Data Recipient”).

Questions or complaints regarding this Privacy Policy should be directed to: support@cosigames.com. We will promptly investigate complaints relating to potential violations of your rights to protect your information or potential violations of this Privacy Policy.

Third Party Sites and Links

The Website and Application may contain links to other websites that are independent, are not owned or operated by Cosi, are not covered by this Privacy Policy and which may incorporate Third Party Information. These third party sites have separate and independent privacy policies. If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours. We therefore have no responsibility or liability for the content and activities of other websites, even if they are linked to our Site.

Do we Use Cookies?

We do not use cookies on the Application since it is not a web-enabled product. We may use cookies when you visit our Site. (Cookies are small files that a site or its service provider transfers to your computers hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information).

We may use cookies to compile aggregate data about Site traffic and Site interaction so that we can offer better Site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our Site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. By accessing our Site you are giving your express consent to the use of cookies.

Google, as a third party vendor, uses cookies to serve ads that may be on our Site, which are subject to Google’s privacy policy, not this one. Google’s use of the DART cookie enables it to serve ads to you based on your visit to the Site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

Do we Disclose Personal Data Third Parties?

We do not sell, share or otherwise disclose your Personal Data to third parties other than those parties necessary to fulfill the above purposes, unless you give your prior express consent to receive additional information from Cosi or a third party. This does not include trusted third parties who assist us in operating our Site, conducting our business, administering the Promotion, or servicing you (“Subcontractors”). Our Subcontractors maintain confidentiality of your Personal Data. Our current Subcontractor is Player.IO. We may also release your information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect our or other’s rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. Because our servers, which store your information, are located in the U.S.A., your information may be available to U.S. government entities or agencies under a lawful court order in the U.S.

By accessing our Site, sending us email, registering for the Promotion or otherwise participating in the Promotion, you provide your express consent to our disclosure of your Personal Data to our Subcontractors for the purposes described in this Privacy Policy.

PIPEDA Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the Canadian Personal Information Protection and Electronic Documents Act.

California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.

Children’s Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), as we do not collect any information from anyone under 13 years of age. The Promotion is directed to people who are at least 13 years old or older.

Contacting Us

If you have any questions or comments, or wish to send us any notice regarding this Privacy Policy, please send and email to support@cosigames.com